tra plan summary

TRA PLAN SUMMARY – TOLUENE
BASIC FACILITY INFORMATION
Name & CAS # of Substance
Toluene
108-88-3
Substance for which other Plans
have been prepared
Xylene
1330-20-7
Facility Identification and Site Address
Blue Giant Equipment Corporation
Blue Giant
85 Heart Lake Road South
Brampton, ON
L6W 3K2
Spatial Coordination of Facility
602038m Easterly
4839361m Northerly
Number of Employees
187
NPRI ID
7137
Parent Company (PC) Information
PC Name & Address
Blue Giant Equipment Corporation
Percent Ownership for each PC
(100% owned)
Primary North American Industrial Classification System Code (NAICS)
2 Digit NAICS Code
31-33 - Manufacturing
4 Digit NAICS Code
3369 - Other Transportation Equipment Manufacturing
6 Digit NAICS Code
336990 - Other Transportation Equipment Manufacturing
Company Contact Information
Facility Public/Technical Contact
Mr. Michael Hayes – Vice President of Operations
[email protected]
Phone: (905)-457-3900 ext 245
Fax: (905)-457-2350
Person who Prepared the Plan:
Kaitlin Raheb, P.Eng.
(if different from the
Conestoga-Rovers & Associates Limited
Coordinator)
651 Colby Drive, Waterloo ON
N2V 1C2
[email protected]
Phone: (519) 884-0510
Mr. Michael Hayes – Vice President of Operations
Highest Ranking Employee
[email protected]
Phone: (905)-457-3900 ext 245
Fax: (905)-457-2350
Company Name
Facility Name
Facility Address
078665Misc-Plan Summary-Toluene
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Planner Responsible for Making
Recommendations
Planner Responsible for
Certification
Planner Information:
Kaitlin Raheb, P.Eng
Conestoga-Rovers & Associates Limited
651 Colby Drive, Waterloo ON N2V 1C2
Planner License No: TSRP0009
[email protected]
Phone: (519) 884-0510
Kaitlin Raheb, P.Eng (Licence TSRP0009)
[email protected]
Phone: (519) 884-0510
Fax: (519) 884-0510
TOXIC REDUCTION POLICY STATEMENT OF INTENT
Blue Giant Equipment Corporation (Blue Giant) Brampton facility (Facility) uses toluene in two
processes. The Facility does not intend to reduce the use of this toxic substance at the Facility.
REDUCTION OBJECTIVES
Blue Giant produces high quality products in an environmentally responsible manner. Blue Giant’s
manufacturing operation has been optimized to minimize the use of raw materials. Blue Giant will
strive to reduce the use of toluene at the Facility in the future should an option become available.
DESCRIPTION OF FACILITY
Blue Giant produces elevated loading docks. The main manufacturing process consists of cutting,
welding and painting metal to produce a variety of loading docks.
The North American Industry Classification System (NAICS) Code that applies to this Facility is 333920 –
Material Handling Equipment Manufacturing.
In 2014, the Facility operated their manufacturing process from 6:00 a.m. to 2:30 p.m., 6 days a week,
up to 52 weeks per year.
TOXIC SUBSTANCE REDUCTION OPTIONS
After looking into the seven categories of toxic substance reduction options, no options were
identified. Explanations are provided in the table below to detail why an option could not be identified
in each category.
078665Misc-Plan Summary-Toluene
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Toxic Substance Reduction Category
1) Materials or feedstock substitution
Option: Identification and Description
No option identified: The Facility has considered switching their
current paint to water-based, high solids paint or powder coatings;
however, it was identified that these materials would either
require the product to be cleaned before application and/or
require a much longer curing time with a heating section. The
Facility requires a fast curing paint as part of their current
manufacturing process and due to critical building size limitations;
therefore a switch to an alternative paint is not a viable option at
this time. Alternative coating materials will be revaluated in the
next 2-5 years, when the Facility plans to expand their operations
and move to a larger facility.
The Facility plans to continue to increase their dock leveler and
elevating dock production operations by 15 percent each over the
next few years. As a result, the Facility expects to increase the
volume of paint used, and therefore increase the amount of
toluene used and released to air.
2) Product design or reformulation
No option identified: Blue Giant's business is based on customer
contracts and in meeting market competition. This includes
meeting competitive architectural and engineering specifications
regarding the product design, longevity of the product and raw
material used. A change to the product design or reformulation is
not possible under the existing customer contracts or competitive
conditions.
3) Equipment or Process Modification
No option identified: The Facility equipment and manufacturing
processes are currently optimized to produce final products that
meet client specifications. Replacing the existing paint products
used with high solids or water-based paint products or powder
coatings (as mentioned in Category 1) would have a ripple effect
on the Facility’s equipment and processes, requiring the
installation of wash stations, filtration, and curing stations. The
Facility does not currently have the space for these additional
pieces of equipment.
There are currently no modifications available to be made to the
equipment/process that use toluene that would result in a
reduction in its use.
078665Misc-Plan Summary-Toluene
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4) Spill and Leak prevention
No option identified: Blue Giant has a documented procedure on
how to handle a spill or leak of paint and has implemented spill
containment units to reduce the potential for leaks. Procedures
are posted on the floor in designated locations and are
communicated to the team through training. The Facility also
indicated no spills have occurred in 2013, or since.
5) On-site reuse or recycling
No option identified: The paint spray booths are equipped with a
cleaning system that uses solvents to clean out their spray
equipment when a change in paint is required. The excess paint
and cleaning solvent is sent off-site for solvent recovery or
disposal. The Facility may purchase recycled solvent back from the
off-site facility and use it in their operation, however, this is not
considered a reduction option per the terms of the MOE TRA due
to the recycling occurring off-site. It is Blue Giant’s opinion that
the use of recycled solvent from an off-site source should be
considered when implementing toxic reduction plans.
6) Improve inventory management or
purchasing techniques
No option identified: Blue Giant uses a database management
system to track quantities of products being received on-site and
production demands. Therefore no surplus storage exists at the
Facility. The Facility is unable to identify a reduction option related
to improved inventory management or purchasing techniques, as
they are already doing everything possible in this category.
7) Training or improved operating
practices
No option identified: Blue Giant currently has standard operating
procedures and practices in place at the Facility. All employees are
trained on the facility procedures and practices, as well as on the
efficient use of process equipment. Operating practices and
training procedures are reviewed and updated as necessary and
area for improvement will continue to be evaluated on a regular
basis. Therefore, no options have been identified for the category
at this time.
PLAN SUMMARY STATEMENT
This plan summary accurately reflects the content of the toxic substance reduction plan for toluene.
CERTIFICATION BY HIGHEST RANKING EMPLOYEE
Attached.
CERTIFICATION BY LICENSED PLANNER
Attached.
078665Misc-Plan Summary-Toluene
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